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Housing the Poor? A Comparative Study of Public Housing Provision in New
York, Hong Kong, and Shenzhen
Xin Lia and Shomon Shamsuddinb*
a Department of Architecture and Civil Engineering, City University of Hong Kong, Kowloon,
Hong Kong SAR, China
b Department of Urban and Environmental Policy and Planning, Tufts University, Medford,
MA, USA
*Corresponding author. shomon.shamsuddin@tufts.edu
ABSTRACT
Governments in cities and countries around the world are faced with housing affordability
problems, which acutely affect lower income residents. Prior comparative work adopts a
national perspective that primarily draws upon theories of the welfare state and Western
political ideologies to understand government responses to social problems. However, such
work often overlooks alternative political systems, the distinctive role of housing policy, and
local government strategies. This article compares the provision and role of public housing
across three global cities that are experiencing major housing affordability challenges:
New York, Hong Kong, and Shenzhen. Based on a review of agency documents and housing
and demographic data, we describe public housing policy priorities and examine how the
respective governments administer public housing programs. We find each case shows a
strong demand for public housing, a broad interpretation of target population, and evolving
relationships between the public and private sectors. There are important differences in
policy priorities, program eligibility, management, and over- lap with the private housing
market. The findings suggest standard frame- works may miss variation within countries and
the changing role of cities in providing housing for low- and middle-income households.
KEYWORDS
affordable housing; local government; housing needs; public housing; public-private
partnerships; rental subsidies; social policy; welfare state
To cite this article (Chicago 16th): Li, Xin and Shomon Shamsuddin. 2022. “Housing the
Poor? A Comparative Study of Public Housing Provision in New York, Hong Kong, and
Shenzhen.” Housing Policy Debate. DOI: 10.1080/10511482.2021.2019080.
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Introduction
Housing affordability is a major problem for governments in cities and countries around the world.
House prices have increased faster than incomes in more than 80% of advanced economies (IMF,
2020). The growing gap between housing costs and earnings is especially pronounced in urban
areas: home prices increased by an average of 24% whereas income increased by 8% in 32 major
cities worldwide in recent years (Kallergis et al., 2018; Knight Frank, 2019), and apartment rents
continue to rise even in places with the highest rents (Reid, Nicol, & Allen, 2019). Cities like New
York and Hong Kong regularly appear on lists of places with the most expensive housing, and other
cities, like Shenzhen, are quickly climbing the ranks (e.g., Fleming, 2019; Siebrits, 2019).
Governments operating in different social, economic, and political contexts face challenges in
meeting the housing needs of residents, especially lower income groups.
Scholarly work argues that government approaches to addressing social concerns align with
Western political ideologies about welfare. The liberal, corporatist, and social democratic welfare
regime typology (Esping-Andersen, 1999, 1990) is a prominent framework that is based on countries in
Europe and North America and regularly used for comparative analysis of social policy. However,
there are important approaches to welfare in other parts of the world (e.g., East Asia) that may not
neatly fit into the typology (e.g., Doling, 1999; Wang & Murie, 2011). Further, the typology
overlooks the distinctive role of housing policy within the welfare state: housing typically requires
much higher capital investment and housing assistance is rarely provided to all who are income
eligible (Doling, 1997; Kemeny, 1995, 2001). In addition, the typology may miss variation in policy
approaches that occurs within countries at the local or regional level, as shown in many policy areas
(e.g., Hawkins, Krause, Feiock, & Curley, 2016; Jeffery, Pamphilis, Rowe, & Turner, 2014;
Myers et al., 2001; Powell & Boyne, 2001; Ratigan, 2017; Trydegård & Thorslund, 2010). In
nations with widely different welfare regimes, local governments routinely use public housing to
address affordability problems. As global cities converge into market-oriented housing systems,
municipal governments play a larger role in mitigating rising housing inequality (Chen, Yang, &
Wang, 2014), and so there is a need to study housing welfare provision at the city level.
This article presents a comparative study of the provision and role of public housing across
three cities: New York, Hong Kong, and Shenzhen. All three are global cities experiencing
market pressures and notable housing affordability challenges, despite different political,
economic, and social arrangements. Based on a review of official agency documents and local
housing and demographic data, we describe recent public housing policy priorities and examine
how the respective governments administer their public housing programs. We find each case shows
strong demand for public housing, a broad interpretation of preferred target population and
resident composition, and evolving relationships between the public and private sectors. There are
important differences in policy priorities, program eligibility, management, and overlap with the
private housing market. The findings suggest standard frameworks may miss variation within
countries and the changing role of the welfare state in providing housing for low- and middle-
income households. The article also contributes to the literature by revealing differences in city
perspectives on public housing policy priorities, identifying similarities in public housing
program approaches despite differences in population and context, and highlighting the need to
expand welfare regime theory in comparative housing policy research.
The rest of this article proceeds as follows. The next section describes the welfare regime frame-
work in more detail and reviews the relevant literature on comparative studies of public housing.
Then, we present the local government data and records used in our analysis. The following sections
provide an overview of the public housing programs in each city, compare and contrast their
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characteristics, and discuss the implications for housing policy.
Literature
Conceptual Frameworks
What role do governments play in addressing social concerns? In his influential work, Esping-
Andersen (1999, 1990) classifies nations into three welfare regimes: liberal, corporatist, and social
democratic.1 Each regime displays different weights and responsibilities assigned to the welfare
state, market, and family to manage social risks. In liberal welfare regimes, the state offers minimal
welfare protections. Instead, a residual welfare system is used to solve market failures, including
addressing the unmet needs of socially disadvantaged groups. In corporatist welfare regimes,
benefits are often related to earnings and the impact of redistribution is small. Families play a
prominent role in providing support. In social democratic welfare regimes, universal benefits are
provided that are relatively generous in comparison with other systems. The state is the primary
actor in intervening for redistribution and promoting equality (Esping-Andersen, 1999, 1990).
However, other scholars question the number and types of welfare states that accurately describe
countries (Arts & Gelissen, 2002; Holliday, 2000; Scruggs & Allan, 2006).
Some prior work has examined places outside of the original set of mostly Western
industrialized countries, while also recognizing the distinctive role of housing policy. Socialist
states take full control of the housing supply and complete ownership of housing stocks,
allocating housing through work units to households on an as-needed basis in the form of low-
cost rentals (Friedmann, 2005). In recent years, some countries with socialist legacies have
gradually dismantled their universal housing welfare systems through privatization and
commodification of social housing (Kemeny, 1995; Lux & Sunega, 2014; Tsenkova, 2009). The
major changes to urban housing policy in China since the 1990s indicate a potentially unique
hybrid approach to housing provision, which uses land and housing resources to leverage
economic goals and maintain social stability, as opposed to the conventional market-based,
residual, or corporatist approaches (Wang & Murie, 2011; Zhou & Ronald, 2017). One study
suggests that Hong Kong, Singapore, South Korea, and Taiwan may represent a new regime type
in their approach to housing policy: corporatist in production and liberal in consumption, as the
private sector plays a primary role in housing construction whereas the state is more involved in
how housing is allocated and who occupies it (Doling, 1999). This prior research on housing policy
raises important questions about approaches to housing provision.
Housing Provision
Other work uses different dimensions to understand how national governments provide housing.
Kemeny (1995) identifies two rental systems, unitary and dualist, which may be associated with
collectivist and individualist ideologies, respectively. In unitary systems, public or social housing is
available to a wide range of residents and competes with a regulated private rental housing sector. In
dualist systems, public housing is restricted to lower income households and its provision is residual, so
it does not overlap with the private rental housing sector.2
Despite the different welfare systems and contexts, nations typically coalesce around a few forms
of housing welfare provision: subsidized rental housing and subsidized housing for sale.3 Subsidized
rental housing is primarily intended for the neediest households in Anglo-Saxon countries (Kemeny,
1995). However, the availability of state-provided low-cost rental housing in those countries has
diminished; low-income households are instead encouraged to look for housing in the private sector
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either through rental subsidies for tenants or rent control regulations imposed on landlords. Studies of
East Asian cities such as Hong Kong and Singapore find the government has a dominant role in
providing rental housing to a large proportion of citizens (Huat & Wong, 2018; Lui & Suen, 2011).
China’s transition from socialist universal rental provision to commodification of housing assets may
have diminished housing support for economically and socially disadvantaged groups (Wu, 2018).
The other type of housing welfare provision is intended to promote homeownership under
the assumption that a more secure housing tenure could facilitate community building, social
coherence, and household asset-building capability (Belsky & Duda, 2002; Shlay, 2006). For example,
the U.S. government offers large incentives for homeownership in the form of tax policies, home
insurance, and favorable mortgage terms, but sale of public housing units to tenants is limited
(Megbolugbe & Linneman, 1993; Rohe & Stegman, 1992). Public housing programs designed to
encourage homeownership in Hong Kong are intended to help low-income households climb up the
public rental and subsidized ownership housing ladder (Wong, 2015). Government-subsidized
ownership programs in China are designed to stimulate economic development through housing
construction and consumption (Chen, Huang, & Huang, 2019).
Comparative Studies of Public Housing Policy
Comparative housing research often uses a country-level unit of analysis, but the structure of
housing provision across cities is important to consider. On a city-state scale, comparative studies of
public housing policy often include Hong Kong and Singapore as cases (e.g., see Chiu, 2008;
Doling, 1999; Lam, 2000; Lee, 2003; Yeung & Drakakis-Smith, 1974), partly because these
places have two of the largest systems of public housing, as measured by the proportion of the
population living in government housing, and high rates of economic growth through the 1970s and
1980s (Castells, Goh, Kwok, & Kee, 1988). Despite a long history of public housing in the United
States and the relative success of the program in places like New York (Bloom, 2008; Marcuse,
1986), it is rarely the subject of comparative study (for exceptions, see Goering, 1993; Hananel,
Krefetz, & Vatury, 2018). Changes in housing policy in China have stimulated recent work on
national housing reforms and public housing provision schemes in major cities (e.g., Chen et al.,
2014; Wang & Murie, 2011; Zhou & Ronald, 2017), but Shenzhen is a newly emerging global
city that is typically overlooked.
There are several important challenges for comparative studies of public housing, including
differences in context and terminology. One potential challenge is the identification of a housing
culture, which can be abstract and influenced by past development strategies and economic goals
(Austin, Gurran, & Whitehead, 2014; Lee, 2003). Another potential issue is language and
terminology. For public housing, “the term public has retained a central ambiguity, referring at
once to the sponsor of an act or place (a public authority) and to the intended beneficiaries (the
public)” (Vale, 2000, p. 3). Among geographically proximate Asian countries, the term public
housing has various meanings and uses, such as rental and ownership housing directly provided
and funded by the government, only rental housing produced with government subsidy for low-
income groups, and others (Chiu, 2013). In this article, to allow comparison across cities that
have evolved under distinctive political and institutional backgrounds, we focus on conventional
public housing, which is primarily publicly funded, owned and often managed by a local government
agency, and intended for lower income families.
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Materials and Methods
This article offers a comparative study of public housing provision in New York, Hong Kong, and
Shenzhen. The three places have important similarities: all are prominent global cities, business and
financial centers, and major transportation hubs (see Table 1). New York and Hong Kong have
similar population sizes whereas Hong Kong and Shenzhen are close in population density. Shenzhen
and Hong Kong have comparable levels of gross domestic product. New York and Shenzhen have
similar average residential property prices whereas Hong Kong and Shenzhen are close in house
price-to- income ratio. Each city has attracted millions of workers and large amounts of capital, which
have put serious pressure on the local housing market. New York, Hong Kong, and Shenzhen
have some of the most expensive housing in the world, as well as growing affordability problems
for lower income households. Finally, the cities have strong public housing programs with long
traditions or public support or both. They have preserved or expanded their public housing stock, in
contrast with the trend in other places around the world to reduce it.
Table 1. Demographic and economic characteristics of New York, Hong Kong, and Shenzhen.
New York
Hong Kong
Shenzhen
Population (million)
8.4
7.5
13.0
Land area (km2)
783.8
1,106.7
1,997.5
GDP (US$ billions)
937a
363
366
Global financial center index rank
1
3
9
Airport passenger traffic (million)a,b
62.6
71.4
52.9
Average house price (US$)a
674,500
1,235,220
680,283
Average price per square foot (US$)a
526
2,091
726
House price-to-income ratio
12
41
40
Affordability index
1.13
0.39
0.31
House-price index (2010 = 100)
104
191
~150c
Note. All figures are for 2018 unless otherwise noted. aThe New York City gross domestic product (GDP)
figure is for 2017. Airport passenger traffic, average house price, and average price per square foot are for
2019. bThe figures are for John F. Kennedy International Airport, Hong Kong International Airport, and
Shenzhen Bao’an International Airport. cThis figure is estimated.
Sources: Census and Statistics Department of Hong Kong; Shenzhen Statistics Bureau; U.S. Census Bureau;
Federal Reserve Bank of New York; Airports Council International; Coldwell Banker Richard Ellis;
China Development Institute and Z/Yen Partners; NUMBEO database; The Economist’s Global Cities
House- Price Index.
To analyze and assess the role of public housing across the three cities, we draw upon multiple
sources of publicly available data. The primary source of data is official records and documents from
the agencies responsible for administering public housing in the respective cities. The agencies are
the New York City Housing Authority (NYCHA), the Hong Kong Housing Authority (HKHA), and
the Shenzhen Municipal Bureau of Housing and Construction. Key documents of each city include:
(a) the NYCHA Annual Plan, Property Directory, Development Data Book, and Resident Data Book;
(b) Hong Kong Housing Authority Annual Reports and the Hong Kong: The Facts (Housing)
publication; and (c) the Shenzhen Municipal Housing Security Development Plan and
Comfortable Housing Project Annual Plans for Shenzhen.
Quantitative housing data primarily come from the New York City Housing and Vacancy
Survey, HKHA website, and Shenzhen Real Estate Information Network. Socioeconomic and
demographic data were extracted from censuses and statistical yearbooks, including the U.S.
Census and American Community Survey; statistical reports from the Census and Statistics
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Department of Hong Kong; and Shenzhen Statistical Yearbooks and multiple reports of the
Shenzhen Five-Year Plan. All of these materials are publicly available and were collected from the
respective agency websites.4
Placed in the respective housing policy contexts of the three cities, our comparative analyses
adopt the framework of the structure of public housing provision (Ball & Harloe, 1992; Chen et al.,
2014; Kemeny & Lowe, 1998) by focusing on city-level public housing policy in terms of
responsible public agency, housing program target group, eligibility rules, recent changes in policy
orientation, rental level, demand–supply situation, and finance.
Public Housing in New York, Hong Kong, and Shenzhen
New York City
Housing Policy Context. Public housing in the United States was constructed with federal funding and
is typically managed by local agencies called public housing authorities (Schill, 1993; Vale,
2000). The total number of units in the country peaked at 1.4 million, but the federal government
has instituted a moratorium on new construction of conventional public housing projects (Hays,
1995; Schwartz, 2021). Since then, more than 250,000 units have been removed, including the
demolition of nearly 100,000 units through grants from the federal government; public housing
authorities have partnered with private developers to replace the demolished projects with a wide
range of mixed- income housing developments (Goetz, 2013; Vale & Shamsuddin, 2017). The
result was a reduction in both the size and the visibility of public housing (Vale, 2013).
The history of public housing reveals that “[p]ublic housing was not, at its outset, low-
quality housing for lower-class people, but middle-class housing for working people” (Marcuse,
1986, p. 354). Eventually, federal, state, and local agencies instituted policy changes that
prioritized lower income households, as public housing was treated as the housing of last resort for
the poorest Americans (Spence, 1993; Vale, 2000). Tenant rents, which were previously set at fixed
amounts and covered the costs of building maintenance and operations, were changed to a
percentage of resident income (Schwartz, 2021). These policy changes resulted in decreased rental
income for public housing authorities and increased the need for federal subsidies. However, in recent
decades the U.S. Congress has reduced federal funding for public housing operations and capital
improvements (Bell & Rice, 2018). These funding shortfalls have led some public housing
authorities to explore new revenue sources, management approaches, and private sector partners.
Public Housing Provision in New York. Established in 1934, NYCHA is the local housing
agency that administers the public housing program and other affordable housing programs in New
York City. NYCHA is by far the largest of the nearly 3,000 public housing authorities in the United
States; it is responsible for approximately 15% of the nation’s public housing. It is also the largest
landlord in New York City, with almost 175,000 housing units under its control. NYCHA provides
housing across all programs for more than half a million people, which is equivalent to
approximately 1 in 15 New York City residents. NYCHA public housing residents reside in nearly
8% of all rental housing units in the city (NYCHA, 2019).
Public housing tenant selection and preferences are important aspects of NYCHA’s role in
public housing provision. In its early decades, NYCHA carefully screened applicants and used
stringent selection criteria that excluded lower income households from receiving public
housing. Rents were set below the level of private market units but nonetheless high enough to
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cover all costs, including operating costs, building maintenance, and repayment of debt for land
acquisition and construction (Marcuse, 1986). By the late 1960s, NYCHA had followed many
other public housing authorities in changing its policies and procedures to house poorer tenants
and other vulnerable groups. Currently, NYCHA has preferences for specific groups of public
housing applicants; these priority subpopulations include homeless families, homeless
individuals with HIV, households displaced by fire, victims of domestic violence, and applicants
with a family member cooperating in a criminal investigation who has also been subject to
witness intimidation (NYCHA, 2019).
Eligibility for NYCHA-assisted housing is means tested, consistent with federal regulations.
The U.S. Department of Housing and Urban Development (HUD) requires that households
entering public housing be low-income households, defined as having income below 80% of the
area median income, with additional considerations for households considered very low-income,
defined as having income below 50% of the area median income. Further, at least 40% of new
admissions into public housing in any year must have incomes of less than 30% of the area median
income or the federal poverty level, whichever is lower. In New York City, the upper limit to be
considered low-income is $63,700 for a one-person household and $90,950 for a four-person
household in the year 2020. The very low-income limit would be approximately $40,000 for a one-
person household and nearly $57,000 for a four-person household. In fact, many existing public
housing residents have far lower incomes than the government-set limits. According to NYCHA,
the average income for a family living in New York City public housing is approximately $26,000
(see Table 2).
In contrast with the typical approaches by other public housing authorities in the United States
to exclusively focus on poor households, NYCHA has continued to pursue a strategy of income
diversification among residents (Bloom, 2008). The strategy seeks to bring together public housing
households at different income levels within the range considered low income, which may
encourage upward economic mobility and reduce concentrated poverty.5 NYCHA even has
application preferences for households with at least one member working for pay and has
established assignment tiers based on family income. In recent years, nearly half of new-tenant
families are employed (NYCHA, 2019).
Table 2. Public housing provision in New York City.
Public housing stock
No. of buildings
2,351
No. of units
173,762
8% of all city rental units
Household characteristics
Resident population
365,806
4% of all city residents
Total no. of households
162,721
On fixed income
67,379
41%
On welfare
19,981
12%
Employed
74,375
46%
One parent with children
14,220
9%
Average gross income
$25,727
Average gross rent
$550
Average years in public housing
24
Sources: New York City Housing Authority Resident Data Book 2020; New York City Housing Authority Fact
Sheet 2019.
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Further, some residents may no longer be considered low-income households. An audit by
HUD found that almost 11,000 NYCHA households earned more than the public housing
eligibility threshold (U.S. Department of Housing and Urban Development Office of Inspector
General, 2015). Households are permitted to continue living in NYCHA housing if their incomes
exceed the initial eligibility limit at application. Indeed, NYCHA encourages higher income
families to stay in public housing with the belief that they provide positive examples and
pay higher rents. However, the presence of relatively high-income households in scarce
government-subsidized housing units has raised concerns about equity, especially given the
tremendous affordable housing needs.
The amount of rent that residents of NYCHA public housing pay is typically based on their
income. Tenants usually pay either 30% of their adjusted monthly income or 10% of their
unadjusted monthly income toward rent, whichever is higher. Adjustments to income include
deductions for dependents, childcare, and disability assistance. The average monthly rent for
NYCHA public housing households is a little more than $500 (NYCHA, 2019). Some NYCHA
tenants pay a flat rent for their unit, regardless of income, which can be approximately $1,250 for
a studio apartment and nearly $1,500 for a two-bedroom apartment. By comparison, the
estimated gross median rent for New York City in 2018 was $1,443 according to American
Community Survey data, but this estimate is only for occupied units and is skewed downward
because it includes rent in public housing, rent-regulated units, and other subsidized housing.
Various companies report the median rent for apartment listings in New York City in 2018 was
approximately $3,500.
There continues to be strong demand for publicly assisted housing in New York. When the
aptly named First Houses, the first public housing built in New York, opened in 1935, nearly
4,000 families applied for the 122 available apartments (Sribnick, 2012). NYCHA reports that
more than 180,000 households are currently on the waiting list for public housing, down from
approximately 250,000 a few years ago (NYCHA, 2019). Official wait times are not available but
anecdotal reports indicate households can be on the waiting list for 10 years or more before they are
selected, given that the turnover rate for public housing apartments was recently less than 3%. Once
they receive and accept a housing offer, NYCHA residents stay in their homes for an average of
24 years (NYCHA, 2019).
Despite the demand, NYCHA has not engaged in new construction of additional public housing
units (i.e., that would lead to a net increase in the number of NYCHA units), because of a prohibition in
federal law.6 Over the years, it has remained committed to preserving its precious stock of public
housing and mostly avoided the large-scale demolition of residential buildings (Bloom, 2008).
However, most of the public housing projects in NYCHA’s portfolio are more than 50 years old and
overdue for upgrading or replacement of major building systems. The capital needs backlog is
estimated at $40 billion, which is due in part to aging buildings combined with years of declining
federal support and policy changes that have reduced rental income. In NYCHA’s public housing
operating budget, roughly 43% of revenue is from tenant rent payments, 41% is from federal
government subsidies, and the rest is from city government funds, parking fees, commercial rental
income, community center revenue, and other sources.
To address growing management, repair, and funding needs, NYCHA has explored partner-
ships with the private sector. For example, NYCHA has hired private property managers to
manage almost 8,500 housing units in an attempt to reduce costs and has designated private
developers and property management companies to renovate nearly 6,000 units (NYCHA, 2020).
In addition, NYCHA is participating in the HUD Rental Assistance Demonstration program to
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leverage private financing to repair and upgrade almost 62,000 public housing units (Office of
the Mayor, 2018). Further, NYCHA has solicited proposals from private developers to build new
residential projects on undeveloped land in exchange for lease payments that would be used to
pay for repairs and capital improvements to public housing buildings (Shamsuddin & Vale,
2017; Smith, 2013).
Hong Kong
Housing Policy Context. The practice of public rental housing (PRH) provision in Hong Kong began in
the 1950s during the British colonial period, as a result of resettlement attempts after a fire in a slum
area (Yung, 2008). Whereas early housing projects mostly helped relocated families because of slum
clearance and resettlement, the Ten-Year Housing Program launched in 1972 shows the colonial
government’s commitment to providing public rentals for means-tested low-income families in
general over the following 10 years. One important event is the establishment of the HKHA in
1973, a government agency in charge of the city’s public housing programs. PRH units allocated
during that period have a lifelong and inheritable tenancy tenure regardless of any changes in
occupants’ social and economic situation. As ambitious as it was, the government made an official
announcement of the failed Ten-Year Housing Program in 1980, two years before its planned year for
completion, that less than 40% of the intended target of housing 1.8 million people was achieved
(Deng, Chan, & Poon, 2016).
The Home-Ownership Scheme (HOS) enacted in 1976 marked the policy initiative to
encourage homeownership for well-off households. The government’s intention to promote
homeownership became more evident throughout the 1987–2002 period, during which potential
homebuyers were offered various loan supports to buy flats on the private market or from
government-built developments. One significant policy is the promulgation of the Long-Term
Housing Strategy in 1987, aiming to build over one million public and private units for sale by 2001
and to achieve a 60% ownership rate by 1997 (LEGCO, 2013). Under the HOS and Tenant Purchase
Scheme (TPS) enacted in 1998, project-based public housing estates were newly built each year,
offering sitting tenants or eligible families the option to purchase flats at deeply discounted prices.
Since 1998 (Hong Kong became a special administrative region of China in July 1997), all public
housing applicants have been required to be means-tested by income level and asset situation,
and the right of public rental inheritance was revoked that year.
Starting in 2002, there was a retreat of the homeownership policy goal; instead, the focus has
turned to public rentals to serve the needy. The production and sale of HOS housing ceased from
2002, with the exception of unsold existing units. The supply of TPS units was also terminated from
2006, although the right to purchase granted to sitting tenants of existing TPS rentals remains active.
This mixed ownership of public housing estates has created frictions between long-term home-
owners and tenants in estate management and maintenance (Forrest & Yip, 2014).
In the 2010s, homeownership returned to the policy agenda, in response to the public outcry
for government support of affordable housing. Although the sales of HOS units (a combination of
HOS and TPS estates) resumed in 2011, low-cost public rentals continue to dominate the
subsidized affordable housing sector. In the discussion of housing provision below, we focus on
PRH.
Public Housing Provision in Hong Kong. The Hong Kong Housing Authority is the primary provider
of public housing in Hong Kong in the forms of PRH and for-sale flats under the HOS or TPS
schemes. The latest data (June 30, 2020) reveal that there were 795,500 HKHA-owned PRH units,
home to 2.1 million people or 780,400 households (see Table 3; HKHA, 2020a, 2020b). The pace of
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constructing PRH has slowed since 2006, to an average of 10,500 units per year between 2006 and
2018. The other provider is the long-established nongovernmental organization Hong Kong
Housing Society (HKHS), which supplies a similar combination of assisted housing estates to HKHA.
Nearly half of its housing stock comprises low-cost rental estates for low-income families, serving
about 83,000 people (HKHS, 2019). It also owns units for middle-income or higher low-income
families (i.e., the sandwiched class) to purchase at affordable prices, and for elderly people to rent on
a lifetime basis. However, compared with the large volume of HKHA housing, HKHS has played and
will continue to play a rather minor role, given its limited housing stock and resources.
Table 3. Affordable housing supply and current stock in Hong Kong (units), 1980–2019.
Public rental housing
(PRH)
Home-Ownership Scheme
(HOS)
Tenant Purchase Scheme (TPS)
Period
Sold units
Rental units
Pre-1980
184,300
13,453
—
—
1981–1990
131,100
127,538
—
—
1991–1997
109,200
115,475
—
—
1998–2000
74,900
40,763
69,570
12,538
2001–2005
102,700
15,103
73,678
28,250
2006–2010
52,200
17,194
2,575
—
2011–2015
53,400
3,078
1,396
35,966
(current stock)
2016
17,500
2,657
231
2017
9,800
2,120
184
2018
14,700
4,431
202
2019
2,405
4,904
234
Total
752,205
346,716
148,070 40,788
184,036
Source: Compiled from Annual Reports on Housing in Figures by Hong Kong Housing Authority (HKHA) and
HKHA data about public housing estates, sales of home ownership scheme flats, and list of TPS estates.
PRH in Hong Kong is extremely attractive to a wide range of social groups, including poor
working families, young single workers, elderly people, single parents, and families living with
seniors. Under a centralized application system, applications are categorized into three waiting lists.
One list takes applications by ordinary families, whose income and total net assets must be below
certain limits set up by HKHA, besides other specifics. For example, for a four-person family,
monthly income must be less than HK$29,240 (~US$3,750) and total assets must be less than
HK$530,000 (HKHA, 2020c). The second list prioritizes applications by elderly persons, with a
cutoff age of 60 by the time of successful allocation. Senior applicants are subject to the same income
and asset rules as ordinary families. Besides, the public housing policy values the traditional Asian
nuclear family, where adult children take care of aged parents. Such family applications also receive
priority treatment under the Harmonious Families Priority Scheme. The third list is open to
nonelderly one-person applicants under the Quota and Points System introduced in 2005. Points are
calculated based on the applicant’s age and the waiting time. Each year, around 8%–10% of total
PRH flats are reserved for this list. This separate list on the one hand likely increases the chance of
success for a young single person, and on the other hand stimulates potential demand for PRH as it
encourages young people to apply as soon as they turn 18.
Thanks to its low cost, decent quality, and high tenure security, there is little doubt that PRH is
the best alternative for families who cannot afford market-rate rent. PRH programs benefit not only
low- income households, but also better off ones. The income limit eligibility rule is quite generous.
For instance, the median monthly income is around HK$17,000, whereas the income limit for a
11
one- person family is $11,830, 70% of the median income (HKHA, 2020d). Every two years,
HKHA conducts a rent review and makes rent adjustments based on any changes in household
income. As of March 2020, PRH rent level ranged from HK$443 to $5,159, with an average rate
of $2,070 per month. Rent differentials between for-profit and publicly subsidized housing have
been aggravated since the 2000s, making more and more asset-poor households reliant on
government provision. Stagnant incomes of renters and increased rents in the private market
exacerbate the shortage of public housing supply. New construction has failed to catch up with
emerging demands. According to HKHA data published in June 2020, general applicants needed to
wait on average 5.5 years to receive a housing offer; elderly single applicants spent less time in the
queue, on average 3 years.
HKHA’s diverse property portfolio allows the self-financed institution to maintain a
balanced account for its construction projects and property management (HKHA, 2020a; Hui &
Wong, 2004). Besides public housing, HKHA also owns and leases market-rate spaces of
commercial and industrial properties, car parks, and converted industrial flats, the profits from
which can be redistributed to subsidize the maintenance costs of public housing estates. The
HKHA 2020 financial statements (HKHA, 2020e) report a total income of HK$46 billion in
2020, of which 45% came from rental collections of residential housing and commercial
properties and 50% from sales of flats. Capital investment in public housing development comes
primarily from HKHA’s own fund reserves established in the 1990s, with free or very cheap land
and capital loans from the government.
Although a public–private partnership approach was proposed to the 2018 Hong Kong
Task Force on land supply to solve public housing shortage (Ho, 2018; Zhang & Ng, 2018), little
evidence has indicated any partnership practices in public housing construction. PRH projects
are still primarily financed by housing authority funds. Regarding property management, the
HKHA introduced a pilot scheme in 1996, through which it began to privatize housing
management services to private management agents (Li & Siu, 2001). Currently, private agents
manage about 60% of HKHA rental estates, and the rest are managed directly by the Housing
Department.
Shenzhen
Housing Policy Context. The 1998 reform of housing commodification empowers local governments
to focus their post-reform housing policies on stimulating real estate investment. China’s socialist
housing welfare was thus replaced by Anglo-Saxon-style neoliberalism in the housing sector, in
which the state withdraws from being the primary provider of housing. Municipal governments, the
de facto owner of state land, became entrepreneur states in land sales to enjoy ever-increasing price
appreciation. Although households ardently invest in apartment purchase in the promising real
estate market, people with limited resources soon realize that they might have been excluded from
this housing boom. However, as housing is becoming increasingly unaffordable in the private
market, there has been an outcry for government support to meet the housing need for low-
income families (Zhou & Ronald, 2017).
The evolution of China’s public housing system has been well documented by a number of
scholars (Chen et al., 2014; Chiu-Shee & Zheng, 2019; Huang, 2012). The oldest so-called
affordable housing policy can be traced back to as early as 1994 under the name of the economically
affordable housing scheme (EAH or jingji shiyong fang), which offers below-market sales to low-
and middle- income households. But the early version (late 1990s and early 2000s) of EAH is often
understood by the public as low-cost commodity housing, because it was not means-tested by
12
income level or subject to any resale restrictions (Huang, 2012). The program has been criticized for
benefiting the privileged with connections to government entities or state-owned enterprises more
than it benefited households under poverty. This ambiguity between economically affordable and
commodity housing persisted until a 2007 policy imposing resale restrictions and reiterating the
means-test targeting policy group—that is, low-income urban households with extremely poor
living conditions (State Council, 2007). Those good policy intentions of the central government
led to a pause in a number of cities on constructing EAH as developers found such investment less
profitable because of these restrictions (Huang, 2012). Consequently, a general shift of housing
policy goal from subsidizing ownership sales to public rentals occurred in many cities.
The oldest stock of PRH comes from the conversion of existing social housing units to
cheap rental housing (CRH or lianzufang), serving the poorest households. The early CRH
program aimed at digesting a historical legacy, rather than meeting the demands of new rural–urban
migrants (Deng, Shen, & Wang, 2011). To house emerging working class migrants, some
municipalities began to construct large-scale PRH (or gongzufang) under the Social Security Housing
system (baozhangxing zhufang) promulgated to municipalities in 2011. Between 2011 and 2015,
China constructed 13.6 million units of PRH (including CRH units), accounting for 34% of the
total government- funded housing projects (State Council, 2016).
Public Housing Provision in Shenzhen. The Shenzhen Municipal Bureau of Housing and
Construction takes full charge of the city’s public housing programs. Shenzhen’s public housing
development strategy is different from that of other cities and is viewed as an exemplary practice in
alleviating housing problems not only for poor households with Hukou but also for poor ones
without Hukou and for skilled migrant workers (China Development Research Foundation, 2012).
13
Shenzhen’s subsidized housing structure experienced major changes around 2010. Before
2010, the three types of subsidized housing were EAH, PRH, and CRH. As shown in Table 4,
between 2006 and 2010, the bureau invested substantial resources in the construction of public
rental estates, supplying 104,729 units, accounting for 62% of the total government-funded
housing projects (SMBHC, 2011). From 2008, CRH statistics disappeared after the CRH program
was integrated into PRH, suggesting that rental stock specifically reserved for very poor house-
holds no longer exists.
From 2013, Shenzhen’s affordable housing system was recategorized into three groups: talent
housing (TH or rencai zhufang), PRH, and comfortable living-style commodity housing (CLCH or
anjuxing shangpinfang), with the latter two officially named social security housing. Social security
housing refers to subsidized housing for low- and middle-income households. As implied in the
names, PRH units are rentals only, CLCH units are for sale only, and TH units are for either rent
or sale. Chen (2018) points out that Chinese cities tend to utilize public housing programs as a tool to
attract specific target groups, rather than for housing the poor. Similarly, programs in Shenzhen are
less oriented toward helping the poorest, and designed more to cherry-pick middle-working-class
professionals who are deemed talents. Although PRH accounts for the largest proportion, TH
construction has caught up in recent years.
New affordable housing projects in the last five years show a much clearer picture of
policy preference (see Table 4). The number of completed TH projects increased every year, from
five projects in 2016 to 59 in 2019. In contrast, the number of PRH projects peaked at 137 in 2017
and then dropped to eight. If we look at the total units under different schemes, 92% of the total
supply in 2019 was allocated to TH applicants, compared with 14% 4 years prior. By the end of
2019, the total stock for talent-based families has almost caught up with that for general public
housing residents. With reference to rent or sales prices of comparable properties in the private
market, PRH costs the least, usually 30% of the market rent, TH is the highest at 60%, and CLCH is
usually half of market prices (SMBHC, 2018).
Like conventional public housing programs, PRH applicants used to be means-tested at least by
income level. As early as 2007, the Shenzhen government first stipulated an income ceiling of a per
capita annual income of less than CNY ¥23,252 and total family assets of less than ¥280,000 for
households to be eligible for PRH (Dong & Li,). In terms of monthly income, this threshold was set at
CNY ¥1,937 (~US$280) per person per month, 93% of the city’s median income in 2007, a quite
generous income threshold. Even more generously, in 2013, the Bureau lifted the restrictions on income
and total assets, making all households of the city’s permanent residents who are not property owners
eligible to apply for PRH. Applicants join the wait list based on the number of years the applicant pays
for social insurance and the approval time of the applicant’s permanent residency (SMBHC, 2013). As
shown in Table 4, after 2008, CRH—which used to target very low-income households—was merged
into PRH (SMBHC, 2016), which means that poor applicants no longer have an exclusive pool of
heavily subsidized housing. Although officials promise to give low-income households priority on the
waiting list, to what extent this promise has been kept is unclear. More recently, in 2019, the income
and asset thresholds were reintroduced as eligibility criteria in the city’s public housing program. The
reality is that the annual supply might not keep up with the increase of the applicant list.
Shenzhen adopts a centralized public housing system administered by the Shenzhen Housing
Security Agency of the Municipal Bureau of Housing and Construction. An online platform, the
Shenzhen Real Estate Information Network, was established to accept applications. Each housing
type has its own waiting list, maintained and managed separately. Supposedly, the three lists should
14
be exclusive because each program sets its own eligibility rules, provides a distinctive segment of
housing, and targets specific social groups. But this is not likely the case. The merging CRH into PRH
might disadvantage low-income households and result in a longer wait time for PRH applicants. This
is primarily caused by the 2013 relaxation of the income restriction for public housing application.
Households of any income, including those who apply for TH or even those who are financially
capable of being homeowners of an affordable unit, can join the rental housing queue. As a result,
the waitlist for public rentals suddenly surged in 2014 and then doubled within 5 years (see Table 5).
Furthermore, there is no obvious evidence showing that priority is given to low-income applicants.
The provision of public housing is primarily the responsibility of the municipal government,
with the Shenzhen Municipal Bureau of Housing and Construction being the executive body.
The construction and maintenance of social security housing and TH are financed by funds
allocated by the municipal government from budgetary revenues. However, in the long run,
although land is often free for public rental projects, government-allocated funds for housing
construction may not be sufficient to meet increasing demand. The housing bureau outsources
property management services to private property management companies, which are only allowed
to charge residents a fee capped by the bureau (Wang, 2016).
Since 2017, the city has attempted to motivate private developers to build public housing
by offering low-cost land in exchange for a predetermined percentage of affordable units in the
development, usually in the form of standalone buildings with shared estate facilities in a large-
scale market-oriented development project (SMBHC, 2017). The type of affordable building—for sale
or for rent under the TH and CLCH programs or for rent only under the PRH program—is agreed
between the developer and the government when land is acquired. For rental units, the developer
would bear the construction cost and the government takes over the building ownership upon
completion. As to for-sale affordable units, the developer is entitled to retain profits generated from
discounted sales. So far, based on our anecdotal data collected from the Shenzhen Real Estate
Information Network, six public–private partnership projects were open for application between
2017 and 2020.
Table 5. Total number of to-be-processed applications for social security housing in Shenzhen,
2013–2019.
Public rental housing Comfortable living-style commodity housing
Sum
2013a
5,161
31,777
36,938
2014
43,712
10,929
54,641
2015
44,308
20,932
65,240
2016
57,637
30,588
88,225
2017
64,279
33,258
97,537
2018
78,333
33,635
111,968
2019
87,637
32,970
120,607
Total
381,067
197,887
578,954
Note: aData available from March 2013.
Source: Shenzhen Municipal Housing and Construction Bureau, 2020.
Highlighting Selected Characteristics
Table 6 summarizes several characteristics of public housing in New York, Hong Kong, and
Shenzhen. NYCHA primarily targets low-income and working households for public housing units.
Similarly, the Shenzhen Municipal Bureau of Housing and Construction provides housing for low-
income house- holds and talented people. The HKHA also uses income as a criterion for public
housing but tends to serve diverse social groups. Shenzhen has the most generous income limit for
15
public housing, whereas New York and Hong Kong are similar in terms of percentage of median
income although the actual dollar value in New York is double that of Hong Kong. Estimated
rent levels are approximately 20%–40% of market rate rents, with the exception of TH in
Shenzhen.
Discussion
A comparative analysis of public housing provision in New York, Hong Kong, and Shenzhen shows
some important similarities, such as demand and target groups, across the three places despite very
different political and cultural contexts. All three cities have many more residents seeking public
housing than available units. Although public housing in the United States is intended for low-
income households, New York City has actively created—and continues to attempt to create—
developments that house residents with a range of incomes, especially employed households
(Bloom, 2008; Kennedy, 1997). The deliberate effort to attract and retain higher income households
is a type of mixed-income strategy and may be part of the reason why New York has rejected the
large-scale demolition of public housing buildings embraced by many other U.S. cities (Bloom, 2008;
Vale & Shamsuddin, 2014). In Hong Kong, a substantial proportion of nonpoor households rely on
subsidized rental accommodation. HKHA-owned buildings house a relatively diverse range of
groups, such as working families, young single workers, single parents, elderly people, and families
living with seniors. Current Hong Kong policies place an emphasis on seniors and households with
seniors. In contrast, in Shenzhen, income criteria for housing eligibility seem to be overshadowed by
alternative policy goals. Subsidized housing programs in Shenzhen have become less oriented
toward helping the poorest, and more designed to cherry-pick middle-working-class professionals
who are deemed talents, as evidenced by the increasing share of TH investment. The TH scheme,
which offers below-market-rate rentals or for-sale homes to certain talented migrants, appears to be
quite effective in retaining local civil servants and highly educated skilled laborers. Overall, all three
cities administer a public housing program purposely designed to house lower income residents, yet
each city intentionally makes allowances for higher income occupants, albeit for different reasons.
16
Each city adopts an expansive view of the target population served by public housing, which may
clash with the high demand from poor households.
Nonetheless, there are important differences in the approaches to public housing provision in
New York, Hong Kong, and Shenzhen beyond the obvious political and cultural differences. Whereas
New York operates a dual rental system consisting of a public housing program that is separate from
private market housing, Hong Kong and Shenzhen seem to move closer to becoming a unitary or
integrated rental market, where the subsidized nonprofit rental sector tends to compete with the
for-profit sector. The expansion of the low-cost housing sector, for example TH in Shenzhen and PRH
investment in Hong Kong, has aimed to make housing affordable to a wider range of social groups
and enable them to climb up the housing tenure ladder.
Other differences are observed in how each place manages and operates its public housing
program. NYCHA has implemented private-sector practices such as site-based management and
asset management approaches to public housing, similar to how privately owned rental housing is
managed (Bavan & Shamsuddin, 2007; Quercia & Galster, 1997). In contrast, HKHA engages in
centralized management of its entire housing portfolio, which consists of public housing,
commercial properties, car parks, and converted industrial flats. For housing units, it has a centralized
waiting list, maintenance, and property management. Similar to Hong Kong, Shenzhen has a
centralized housing system operated by the Municipal Bureau of Housing and Construction. These
management approaches may reflect both political ideologies and economic pressures.
The relationship between the local government and the private sector regarding public housing
is also worth noting across the three cities. NYCHA has actively engaged in partnerships with the
private sector to manage existing public housing, obtain financing, and build new housing, to help
compensate for declining federal funding (Honan, 2018; Kamat, 2019; Schwartz, 2017). Although the
Hong Kong government has rarely leveraged private investment for public housing projects,
because the HKHA receives free land from the government for public housing projects, public–
private partnerships have been recently proposed to address the need for more units (Ho, 2018;
Zhang & Ng, 2018). Public–private partnership in public housing development in Shenzhen is also
rare but on the rise, and the Housing Bureau has increasingly sought partnerships with the private
sector in constructing public housing by using land and construction permits as leverage with
developers. The emerging public–private partnerships suggest the shifting role of local government
in public housing and potentially evolving approaches to welfare.
Implications
The comparative analysis of public housing provision in New York, Hong Kong, and Shenzhen
suggests that conceptual frameworks based on national characteristics may miss important variation
within countries and changes over time. For example, many U.S. cities have actively sought to reduce
the size of their public housing stock through demolition, disposition, and other means (Goetz,
2013). This approach aligns with the typical categorization of the United States as a liberal regime
that offers minimal protections and a residual system. However, New York has worked to preserve its
public housing units, in contrast with national trends. Hong Kong has substantially shifted its policy
priorities and public housing goals over the years in ways that defy simple categorization (Forrest &
Yip, 2014; Lee, 2003). China is considered to have a hybrid approach to housing that draws upon
socialist, social-democratic, and productivist aspects (Zhou & Ronald, 2017). Shenzhen is one of the
first Chinese cities to offer subsidized housing to migrants, both skilled and unskilled. The use of TH
to attract human capital and encourage economic growth suggests a pro-growth approach to its
affordable housing program that is administered by the municipal government. Indeed, applying the
17
welfare regime typology and its variations has limitations in deciphering a society’s housing system,
which, as Stephens (2020) suggests, depends more on the policy choices made by local authorities
than on the type of welfare regime.
The three cities also show how policymakers use different routes to pursue diversification of
public housing residents, either by program target groups or by the mix of residents within
projects. In New York, the housing authority prioritizes maintaining communities with a range of
incomes; higher income households are encouraged to continue living in public housing even
though they may no longer need it. In Hong Kong, the housing authority creates a diversity of ages
and household types through multiple target groups; the sheer size of the public housing program also
ensures that a wide swath of the population is represented. Its public housing sector displays an
unintentional kind of mix where HKHA-owned buildings may house a diverse tenant profile in terms of
age and household type. Yet there is no deliberate policy effort to mix them in particular projects.
Shenzhen’s housing programs pursue class and education diversification through a focus on skilled
laborers that reflects larger economic development goals. But class or education mix within the same
project is seldom realized because housing projects for talents and general applicants take separate
planning and building tracks. Additional research should examine how program target groups, mix
of tenants within projects, and other routes to public housing resident diversification affect outcomes
(Shamsuddin, 2022).
The future of public housing in each city raises important issues. The New York City
government has repeatedly stated its intention to preserve its public housing stock. However,
public housing preservation may need to occur by various means, including through forms of
privatization that may threaten fundamental aspects of public housing itself (Hanlon, 2017; Schwartz,
2017; Shamsuddin & Vale, 2017). New York has thus far mostly avoided demolition of its public
housing projects, but funding gaps have recently forced it to consider this option (Ferré-Sadurni,
2019). Hong Kong plans to build more public housing to accommodate interest, especially from
single-person households— for example, young graduates in their 20s and 30s. However, demand
continues to outpace construction, which is reinforced by limits on allowable buildable land area
and suggests limits to what housing may ultimately accomplish in Hong Kong. Shenzhen is invested
in building more and more public housing to attract young talented workers. However, it will have
to compete with other Chinese cities that have the same goal. Further, the effects of the emphasis
on this subgroup on social relationships and demographics in the long run remain to be seen.
The examples of Shenzhen, Hong Kong, and New York demonstrate the importance of
shifting policy priorities and the changing role of the welfare state in providing public housing.
As housing cost pressures grow in these cities, the local provision of public housing for lower income
households will become even more important and contested. Our findings indicate that standard
national-level con- ceptual frameworks may miss substantial variation within countries and the changing
role of the welfare state in providing housing for low- and middle-income households. The results
also show important differences in city government perspectives on public housing policy priorities and
identify similarities in public housing program approaches despite differences in population and
context. Finally, the findings highlight the need to expand welfare regime theory in comparative
housing policy research.
Notes
1.
Examples of liberal countries include the United States, the United Kingdom, New Zealand,
Canada, and Australia; corporatist countries include Switzerland, Germany, and France; social
democratic countries include Sweden, Norway, the Netherlands, and Denmark.
2.
According to Kemeny (1995), examples of dualist systems include Australia, Great Britain, and
18
New Zealand. Examples of unitary systems include Germany, the Netherlands, Sweden, and
Switzerland.
3.
Direct subsidies to individuals (e.g., renters, homebuyers, or homeowners) are another form of
housing welfare provision.
4.
We provide website links of housing agencies and database platforms in the Reference section.
5.
In addition, the gentrification of neighborhoods surrounding many public housing projects in
New York has created an alternative to the national trends of demolition and dispersal as a
means of deconcentrating poverty (Goetz, 2003; Wyly & DeFilippis, 2010).
6.
Section 9(g)(3) of the United States Housing Act of 1937.
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